On April 22, 2026, the Chemicals Agency (Ministry of Industry and Trade) issued two Official Letters No. 813/HC-CNHC to provide clarification and detailed guidance on several regulations in the chemical sector, particularly regarding the import, export, and management of specially controlled chemicals.
Key points include:
1. Timing for declaration of chemical use purposes:
For conditional import chemicals, enterprises may proactively choose the timing to declare the intended use on the specialized database.
2. Interpretation of “content” and “concentration”
As the Law on Chemicals does not provide specific definitions, these terms are interpreted according to their common dictionary meanings:
- Content: the amount of a substance in a mixture, expressed as a percentage (%)..
- Concentration: the degree of density, expressed as the amount of solute per unit volume or mass of the solution.
3. Regulations on chemical mixtures and licensing
To determine whether a mixture requires a license, enterprises must compare it against the chemical lists under Decree No. 24/2026/NĐ-CP.
If the chemical is contained in household products (consumer goods for daily domestic use), enterprises are exempt from obtaining a License/Certificate even if it contains specially controlled chemicals under Decree No. 26/2026/NĐ-CP.
4. Licensing authority
The Ministry of Industry and Trade is the competent authority for issuance, re-issuance, amendment, and extension of import/export licenses for specially controlled chemicals, except for cases decentralized under Circular No. 01/2026/TT-BCT.
5. Transactions with export processing enterprises
The purchase and sale of chemicals between domestic enterprises and export processing enterprises shall be carried out in accordance with separate guidance in Official Letter No. 597/HC-QLHC dated March 27, 2026. Specifically:
Export processing enterprises are considered separate customs territories. The management of export activities in these areas is governed by Articles 56, 57, 58, and 59 of the Law on Foreign Trade Management 2017:
- Exports: Management measures apply when goods are moved from a separate customs territory to foreign countries, but not when goods are moved from the domestic market into such territory (however, they remain subject to customs supervision).
- Imports: Management measures apply when goods are moved from a separate customs territory into the domestic market, but not when goods are transported directly from abroad into such territory (except for prohibitions, temporary import suspensions, or quarantine measures).
- Transactions between separate customs territories: Not subject to foreign trade management measures but remain under customs supervision.
(According to Official Letter No. 813/HC-CNHC dated April 22, 2026)
Related Services: Chemical Import Procedures
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